GEI’s Policy Recommendations

DEQ’s Climate Protection Program (Cap and Reduce) DEQ's Climate Protection Program

Out of all of Oregon’s regulatory agencies, the Department of Environmental Quality (DEQ) and the Environmental Quality Commission (EQC) have the most substantial climate-focused actions to accomplish by 2022. Under Governor Kate Brown’s Executive Order on Climate (EO 20-04), DEQ and the EQC must develop a program to cap and reduce greenhouse gas emissions from industrial and fossil fuel sources in the state.  Staff attorney Amelia (Amy) Schlusser participated in DEQ’s Climate Protection Program Rulemaking Advisory Committee (RAC), a group of stakeholders convened to inform the development of Oregon’s greenhouse gas regulations. GEI offered policy recommendations to ensure an equitable and effective program.

Related Resources:

GEI’s Comments on Climate Protection Program Draft Rules (October 25, 2021)

GEI’s Comments on Issues Raised in Final RAC Meeting (July 16, 2021)

Joint Comments on Draft Fiscal Impact Statement (July 19, 2021)

Joint Comments on Program Enforcement and Penalty Provisions (June 25, 2021)

GEI’s Comments on Draft Program Rules (June 25, 2021)

GEI’s Comments on Issues Raised in the Fifth RAC Meeting (June 8, 2021)

GEI’s Comments on Regulation of Stationary Sources (May 3, 2021)

GEI’s Comments on Community Climate Investments (March 31, 2021)

GEI’s Comments on Flexibility Mechanisms and Point-of-Regulation (March 1, 2021)

GEI’s Comments on Illustrative Scenarios (December 9, 2020)

GEI’s Comments on Impacted Communities (October 2, 2020)

GEI’s Comments on Cost Containment (October 2, 2020)

GEI’s Comments on Alternative Compliance Options (September 10, 2020)

GEI’s Comments on Program Scope (August 26, 2020)

Transitioning from Fossil Fuels SONY DSC

Fossil fuels continue to dominate the energy sectors in the United States, and without policies designed to transition away from fossil fuels, they will remain dominant for decades to come. GEI is working to hasten this transition away from fossil fuels and toward renewable sources, and encouraging careful planning to avoid creating stranded assets that will disproportionately affect vulnerable communities.

Related Resources:

Analysis of Oregon’s Constitutional Restrictions on Transportation Funding (2022)

Joint Comments on Public Utility Commission Natural Gas Docket—Alternative Scenario Modeling (December 3, 2021)

Joint Comments on Public Utility Commission Natural Gas Docket—Regulatory Tools (October 26, 2021)

Joint Comments on Public Utility Commission Natural Gas Docket—Utility Compliance Modeling (September 24, 2021)

Joint Comments on Public Utility Commission Natural Gas Docket—Utility Compliance Model Design (July 30, 2021)

GEI’s Comments on Public Utility Commission Natural Gas Docket (July 13, 2021)

RPS Repeal Efforts Are Fueled by False Claims

Push and Pull: A Federal Tug of War over Renewable Energy

The Fifth Circuit Eviscerated PURPA in Texas


Least-Risk Utility Resource Planning

GEI’s least-risk planning work aims to promote a transition to effective utility planning that aims to avoid long-term risks typically associated with fossil fuels, rather than focusing narrowly on short-term costs. As part of this work, GEI has produced a report showing how least-risk planning can promote use of more renewable energy. The report also identifies “best practices” for least-risk planning. GEI is working on projects that explore how least-risk planning can address existing investments in renewable power.

Related Resources:

A Safe Bet: How Least-Risk Resource Planning Can Pave the Way for Renewable Energy

Xcel’s Upper Midwest Resource Plan Illustrates the Difficulties of Creating a Long-Term Energy Plan for Multiple States with Divergent Energy Policies

We Must Discourage Electric Utilities from Making High-Risk Investments


Clean Power Plan 

The EPA’s Clean Power Plan requires states to develop plans to reduce carbon dioxide emissions from existing fossil fuel-fired power plants. The rule encourages states to implement an array of strategies to reduce emissions from existing power plants. In addition to controlling emissions directly from affected generating units, the Clean Power Plan gives states the option to reduce emissions through deployment of lower or non-emitting resources, including renewable energy and demand-side energy efficiency. The rule also permits states to participate in market-based emission trading programs with other states. This flexible approach enables states to select the most cost-effective strategies for reducing power sector emissions. However, the available compliance strategies each carry different risks and rewards. States must identify optimal implementation strategies for their own power sectors that will enable the bulk electricity system to maintain reliable operations on a regional scale. GEI is evaluating policies and strategies that will support Clean Power Plan implementation at the state and regional levels.

Related Resources:

States Can Implement the Clean Power Plan Without Compromising Grid Reliability

Integrating the Clean Air Act With Cap-and-Trade


Utility 2.0: Utilities for the 21st Century Wind turbine above olive trees. © Mark Riskedahl

The rapid growth of renewables in the United States has led utilities to fear a “death spiral,” in which they could face ever-increasing costs and ever-declining revenues, ultimately leading them to insolvency. This “death spiral,” however, does not have to occur if utilities and their regulators engage in careful and strategic planning. GEI’s Utility 2.0 work explores the options utilities have for adapting the century-old utility business model to the electricity system of the 21st Century.

Related Resources:

GEI Comments on Hawaiian Distributed Generation Plans

Utility Business Models Evolve Around Renewable Energy

New York’s Proposal to Enhance Customer Engagement


Distributed Generation of Solar Power

Interest in distributed renewable energy generation—particularly from solar photovoltaic systems—had expanded rapidly in the past decade. But policies in many places have not adjusted to support cost-effective, sustained, and equitable development of distributed generation. GEI’s work in this area explores ways to lower the costs of solar and to provide new models of investment in solar power.

Related Resources:

Solar Building Standards: How American Cities Can Lay Foundations for a New Generation of Solar Development

Shrinking Solar Soft Costs: Policy Solutions to Make Solar Power Economically Competitive

GEI Comments on Proposed Securities Exemption Rulemaking

A Trade War Over Cheap Chinese Solar Panels: Protecting American Ingenuity or Needlessly Raising Prices?